PANUPS: Active "Inert" Ingredients

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P A N U P S
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Pesticide Action Network
North America
Updates Service
http://www.panna.org/panna/
EMAIL: panna@panna.org
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July 28, 1997
"Inert" Pesticide Ingredients Pose Hazards
At least 382 of the chemicals on the U.S. Environmental
Protection Agency (EPA) list of pesticide inert ingredients
are or were once registered as pesticide active ingredients.
According to the Northwest Coalition for Alternatives to
Pesticides (NCAP), a group currently undertaking a study of
pesticide ingredients, these pesticidal substances can be
used legally in pesticide products without being listed on
the product label. There are approximately 2,500 inerts on
EPA's list.
U.S. pesticide law defines an inert as any ingredient in a
pesticide product other than the active ingredient. Inerts
are added to perform a variety of functions, including
dissolving a pesticide, helping it stick to its target or
increasing the pesticide's efficacy in some way. Active
ingredients are defined as chemicals which "prevent, destroy,
repel or mitigate any pest." Federal law requires that active
ingredients be listed on the label, but inerts -- which can
comprise up to 99% of the product -- may remain secret.
NCAP's findings indicate that EPA allows manufacturers to use
certain active ingredients as though they were inerts -- NCAP
calls these substances "active inerts." According to NCAP,
the fact that so many "active ingredients can be used legally
in pesticide products without being disclosed on the label
constitutes a major oversight by EPA."
In 1987, EPA announced an inerts strategy it said was
"designed to reduce the potential for adverse effects from
the use of pesticide products containing toxic inert
ingredients." Central to the strategy was the creation of
four toxicity categories. List 1, "Inerts of Toxicological
Concern," includes carcinogens, teratogens and neurotoxins.
EPA stipulated that no new products could use these toxic
inerts and that, in existing products, their use and a
warning must be disclosed on the label. List 2, "Potentially
Toxic/High Priority for Testing," is made up of chemicals
that are structurally similar to List 1 inerts and/or that
had incomplete data sets. List 3 is called "Inerts of Unknown
Toxicity" and List 4 contains substances generally regarded
as innocuous. Inert ingredients on Lists 2, 3 and 4 are not
required to be listed on product labels.
Approximately 70% of the active inerts are found on List 3,
"Inerts of Unknown Toxicity" -- 264 out of the 382 active
inerts. Included in the list are:
-- naphthalene, an insecticidal fumigant that is a common
component of mothballs. According to U.S. Health and Human
Services, it can cause brain damage, convulsions and death in
children,
-- chlorothalonil, a fungicide and a probable human
carcinogen according to the U.S. EPA) and
-- chloropicrin, a fumigant and respiratory tract irritant
that can cause asthma, pulmonary edema, bronchopneumonia and
death.
Butylated hydroxyanisole (BHA) is also among the 1,981
pesticide inerts included on List 3, "Inerts of Unknown
Toxicity." However, in 1987 the International Agency for
Research on Cancer (IARC) classified BHA as a possible
carcinogen, and according to EPA's own criteria, chemicals
that have been assessed as known, probable or possible
carcinogens by IARC qualify for List 1. This discrepancy is
particularly troubling because BHA is a commonly used
antioxidant in butter, vegetable oils, cereals, baked goods,
potato chips, meat products and many other foods.
In 1997, IARC classified two commonly used inerts as known
carcinogens: crystalline quartz silica and cristobalite.
Neither is required to be listed on pesticide product labels,
and, based on information obtained by NCAP from a Freedom of
Information Act request to EPA, crytalline quartz silica can
be found as an inert ingredient in at least 1,560 pesticide
products.
NCAP is calling on EPA to revise their inerts policy to
include the required listing of all ingredients on product
labels regardless of toxicity. In addition, NCAP states that
all chemicals used in pesticide formulations must be subject
to the same health and safety testing requirements as active
ingredients. Under U.S. law, EPA must disclose the identities
of pesticide ingredients that pose "an unreasonable risk of
injury to health or the environment." However, EPA cannot
determine whether a chemical poses such a risk when it has
little or no information.
NCAP will release a more detailed report of their findings
this fall.
Source: Journal of Pesticide Reform, Summer 1997.
Contact: NCAP, P.O. Box 1393, Eugene, OR 97440; phone (541)
344-5044; fax (541) 344-6923; email ncap@pesticides.org;
http://www.efn.org/~ncap.
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